2025 (3) TMI 1966

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....Shri Rajesh Kumar, CIT DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.2955/Del/2024 for AY 2018-19, arises out of the order of the Pr. Commissioner of Income Tax, Ghaziabad [hereinafter referred to as 'ld. Pr. CIT', in short] dated 27.03.2024 against the order of assessment passed u/s 144 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 30.0....

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....al and had filed his return of income for the assessment year 2018-19 on 31-03-2019 declaring total income of Rs. 10,19,601/-. The assessment was completed under section 144 r.w.s. 144B of the Act on 30-4-21 determining total income at Rs. 11,15,55,584/-. In the said assessment, the addition on account of estimation of profit at the rate of 7 percent of turnover in the sum of Rs. 11,05,26,953/- wa....

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.... b) Loans received in the sum of Rs. 65,07,700/- to be treated as unexplained under section 68 of the Act and taxed under section 115BBE of the Act. c) Sundry Creditors are more than the Purchases disclosed in the books, which shows that the entire business is run only from the borrowed funds. Capital account of assessee after drawings is a negative figure. Hence the entire Sundr....

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....rder of the learned AO becomes erroneous and prejudicial to the interest of the revenue. Hence the direction of the learned PCIT in this regard is justified. To this extent, the assumption of revision jurisdiction under section 263 of the Act is hereby allowed. 8. In view of the above observations, the revision order passed by the learned PCIT under section 263 of the Act is modified to the ext....